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DOCKET NO. R2000-1
INTERROGATORIES
FROM UNITED PARCEL SERVICE
TO TIME WARNER, INC. WITNESS STRALBERG
(UPSTW-Tl-1
through 3)
(June 19, 2000)
Pursuant to the Commission’s
Rules of Practice, United Parcel Service hereby
files and serves the following interrogatories
Stralberg:
UPS/l-W-Tl-1
directed to Time Warner,
Inc. witness
through 3.
Respectfully
submitted,
William J. Pinamont
Phillip E. Wilson, Jr.
Attorneys for United Parcel Service
I
Piper Marbury Rudnick & Wolfe LLP
3400 Two Logan Square
18th & Arch Streets
Philadelphia, PA 19103-2762
(215) 656-3310
(215) 656-3301 (FAX)
and
1200 Nineteenth Street, NW
Washington, DC 20036-2430
(202) 861-3900
Of Counsel.
INTERROGATORIES
OF UNITED PARCEL SERVICE
TIME WARNER, INC. WITNESS STRALBERG
UPS/TW-Tl-1.
Refer to page 22 of your testimony,
where you recommend
“[mlixed mail and not handling costs in allied BMC and NonMODS
distributed
that
cost pools should be
broadly over all pools within the respective facility categories.”
Confirm that Non-MODS
(4
not confirmed,
(b)
TO
allied operations
include the Mist cost pool. If
explain fully.
If (a) is confirmed,
provide a detailed description
of how your SAS
programs distribute the mixed tallies in the Mist cost pool.
Cc)
If (a) is confirmed,
the sorting operations,
explain why the composite
recommended
volume variability factor of
by MPA witness Cohen (MPA-T-1)
bound for volume variability of the allied operations,
as the upper
was not used for the Mist cost
pool.
UPS/TW-Tl-2.
Refer to page 22 of your testimony,
where you recommend
“‘[mlixed mail’ costs at allied MODS pools, including empty equipment
broadly distributed
t
distributed
(tallies processed
over all direct tallies, not just Function 1 cost pools.
why the distribution
costs, should be
over the direct costs in all Function 1 MODS cost pools.”
that mixed allied tallies with known operation
key was not limited to Function 1 cost pools.
that
Confirm
in “mdmxoper”)
If confirmed,
are
explain
If not confirmed,
explain why not.
UPS/TW-Tl-3.
recommend
distributed
Refer to page 22 of your direct testimony,
where you
that “‘[n]ot handling’ costs at allied MODS cost pools should be broadly
over direct costs and distributed
mixed mail costs in all MODS Function 1
cost pools.”
-2-
.
INTERROGATORIES
OF UNITED PARCEL SERVICE
TIME WARNER, INC. WITNESS STRALBERG
f
Confirm that the distribution
(4
tallies with known operation
distributed
(tallies processed
explain why distributed
excluded from the distribution
in “mdnhoper”)
does not include
(tallies processed
mixed mail tallies with unknown
key. If not confirmed,
in “mod3alld”).
operation were
explain why not.
Confirm that the “not handling” allied tallies with known operation
(b)
processed
key used to distribute the “not handling” allied
mixed mail tallies with unknown operation
If confirmed,
TO
in “mdnhoper”)
If confirmed,
not confirmed,
are distributed
explain why the distribution
(tallies
over all cost pools, not just Function 1 pools.
key was not limited to Function
explain why not.
-3-
1 cost pools.
If
.
.
I
CERTIFICATE
.
OF SERVICE
I hereby certify that I have this date served the foregoing
mail, postage prepaid, in accordance
document
with Section 12 of the Commission’s
by first class
Rules of
Practice.
m
Attorney for United Parcel Service
Dated: June 19,200O
Philadelphia, Pa.
64160